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Asbestos Removal should take place 3 Years from the date found in the IHM Part I Survey

Technical Newsletter as on 1^st August 2023

Introduction

The EU Ship Recycling Regulation No 1257/2013 (hereafter referred to as EU SRR) entered into force in December 2013 with the deadline to fully comply by 31^st December 2020. Within that timeframe, Shipowners were required to obtain the Inventory of Hazardous Material (IHM) Certificate or Statement of Compliance by contracting expert hazmat approved personnel or companies to perform professionally executed onboard sampling and visual check plan under IHM Part I.

The EU SRR regulation covers 15 Hazardous Materials (13 Hazardous Materials as per Hong Kong Convention and two additional hazardous materials, which is PFOS and HBCDD), with a main concern being Asbestos, which is regulated under SOLAS Regulation II-1/3-5.

What do the SOLAS regulation and related IMO Guidelines state about Asbestos Material onboard vessels & its removal?

Since 1^st July 2002, under the SOLAS Regulation II-1/3-5 it states that all installation of material that contained asbestos substances was prohibited for all ships except for some used in exceptional cases. From 1^st January 2011, any “new” installation of materials which contain asbestos has been strictly prohibited. According to MSC.1-Circ.1374, ships built before 1^st July 2002 are allowed to have ACMs on board. However, the ACMs are only allowed as long as they do not pose a risk to the crew's health. Since 1^st July 2002, new installation of ACMs on board all ships have been allowed only in exceptional cases, and from 1^st January 2011, it has been prohibited to have any new installations onboard.

The removal - assigned to professional asbestos removal companies - SHOULD TAKE PLACE WITHIN A TIME FRAME OF 3 YEARS FROM THE DATE WHEN THE CONTRAVENTION IS FOUND and should be conducted in close consultation with and, where applicable, under the supervision of the Flag State concerned. In such cases, a suitable exemption certificate should be issued by the flag State and Asbestos disposal should be followed as per the local laws and should avoid going against the Basel convention.

LET THE STATISTICS DO THE TALKING.

• According to CTI-Maritec’s database on IHM Part I and Asbestos Surveys, approximately 184 vessels in 2020, 365 vessels in 2021 and 355 vessels in 2022 were found to have contained Asbestos Materials at least one or more locations sampled – Have all these vessels completed their Asbestos Removal?
• From the PSC inspection results registered in the Paris MoU from year 2020 till today, a total number of 73 ships were found with deficiencies and 4 detentions were applied related to Asbestos containing materials and ACM statement of compliance (including exemption). This was due to No ACM statement of compliance and/or improper mitigation plans such as Asbestos Registry requirements, Asbestos Management Plan, Asbestos Abatement Reporting and/or exceeding validity of asbestos to be removed.  – The risk of not taking proper action is very clear!

What are the general requirements to protect your vessels from consequences?

In order to prevent such risk of detainment due to asbestos on board, Ship Owners and Managers must ensure certain requirements are met and actively followed/obtained.

GENERAL CHECKLIST OF KEY REQUIREMENTS WHEN ASBESTOS IS FOUND ONBOARD:

• Complete Asbestos Registry Requirements
• Maintain onboard a professionally developed Asbestos Management Plan
• Apply Asbestos exemption certificate from Flag State
• Contract a professional asbestos removal company to conduct the removal within the 3-year stipulated timeframe and to develop the Removal Report for submission to the Flag State
• Ensure Quality Air Control is executed for all stipulated requirements to make sure your vessel is declared free from Asbestos
• Obtain and securely keep onboard/record of the Asbestos Waste Disposal Certificate
• Update IHM Part I

Handy links to learn more:

• For DNV FAQs on EU SRR IHM Regulations, SOLAS & IMO Guidelines
• IMO Guidelines

Support from CTI-Maritec:

CTI-Maritec provides end-to-end services to cover all your requirements for Asbestos Removal, Asbestos Management Plans and Air Monitoring as per EU SRR and IMO regulations. Benefit from:

• Unmatched expertise in the field:  As a leading service provider in the area of Inventory of Hazardous Materials (IHM) surveys, IHM Maintenance, Asbestos Solutions and Responsible Ship Recycling Supervision, till date, CTI-Maritec has completed HazMat related projects for over 5,000 vessels.
• Speedy Technical Advise and Guidance: Our team of experts are committed to providing speedy and accurate guidance for all your technical queries and requirements.
• Risk Mitigation: We will help guide you with your prerequisites to help with mitigation of risks.
• IHM Maintenance: We currently conduct IHM Maintenance on behalf of ship owner and ship management.

To know more, Click Here to visit our website or write to [email protected]